Privacy Notice

1. Who this notice covers

Japality Limited is the data user for personal data it controls through this website and the email address info@japality.com. This notice is written with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (the “PDPO”) in mind.

Individual Japality apps may collect or process different information. The privacy notice shown in the relevant app or store listing applies to that product. Apple, Google, GitHub, JapaLingo, email providers, and other external services are separate organisations with their own privacy practices.

2. Personal data we may collect

Information you provide by email

• Your name, role, organisation, email address, and other contact details.
• The contents and attachments of your message and subsequent correspondence.
• Project, support, licensing, or commercial information you choose to provide.
• Administrative information created while assessing or managing an enquiry.

Providing personal data is voluntary. If you do not provide a working contact method and enough non-confidential context, we may be unable to review or answer the enquiry.

Basic website records

Like most hosted websites, infrastructure providers may automatically create security and access logs containing an IP address, date and time, requested page, referring page, browser or device information, and technical error details. We use or access such records only where reasonably needed for security, availability, diagnosis, or legal compliance.

Data you should not send by ordinary email

Do not send identity documents, credentials, payment-card details, trade secrets, or third-party confidential information in an initial enquiry. If a proposed project requires sensitive information, appropriate authority, necessity, safeguards, and a secure transfer method must be agreed first.

3. Cookies and analytics

As of the effective date, the corporate website does not set first-party cookies and does not use web analytics, behavioural advertising, tracking pixels, embedded social-media widgets, or externally hosted web fonts. A consent banner is therefore not shown.

Following an external link may allow the destination service to receive technical information such as your IP address and referring page. Its own terms and privacy policy apply after you leave this site.

4. Why we use personal data

We may use relevant and non-excessive personal data to:

• receive, authenticate, assess, route, and respond to enquiries;
• discuss technical fit, project scope, support, licensing, or a business relationship;
• prepare and administer confidentiality terms, proposals, contracts, invoices, and records where a relationship proceeds;
• protect the website, systems, users, rights, and property from misuse or security threats;
• maintain accurate records, resolve disputes, and establish or defend legal rights; and
• comply with applicable law, regulatory requests, court orders, or lawful authority.

We will not use personal data for a new purpose unrelated to the purpose of collection unless we obtain prescribed consent or the use is permitted or required under the PDPO or other applicable law. We do not sell contact details.

Direct marketing

We do not use enquiry details for direct marketing unless the notices and consent required by the PDPO have first been provided and obtained. Any direct-marketing message will offer a way to opt out without charge.

5. Who may receive personal data

Where reasonably necessary for the purposes above, data may be made available to:

• personnel and contractors who need it to review or manage the matter;
• hosting, email, security, storage, communications, and other service providers acting for us;
• professional advisers, insurers, auditors, banks, and counterparties under appropriate duties;
• a successor or participant in a genuine corporate transaction, subject to suitable safeguards; and
• courts, regulators, law-enforcement bodies, or other persons where disclosure is required or permitted by law.

Some providers may process data outside Hong Kong. When appointing a provider, we take practicable contractual or organisational steps appropriate to the service and data to address confidentiality, security, and use for the agreed purpose. We do not represent that every destination has the same privacy law as Hong Kong.

6. Retention and security

We retain personal data only for as long as reasonably necessary for the enquiry or relationship, legal and accounting obligations, security, dispute resolution, and the establishment or defence of rights. When records are no longer required, we take practicable steps to delete or anonymise them or put them beyond practical use, unless retention is required or permitted by law.

We use practicable administrative, technical, and access safeguards appropriate to the nature and risk of the data. No internet transmission, email account, or storage system is completely secure. Ordinary email should not be used for sensitive or high-risk information.

7. Access and correction

Subject to the PDPO, an individual may request access to personal data Japality Limited holds about them and request correction of inaccurate data. A formal data access request should be made using the Privacy Commissioner's prescribed Data Access Request Form (OPS003) ↗ and sent to the Privacy Contact below. Ordinary privacy enquiries do not require the form.

A request should identify the requester and the relevant interaction clearly enough for us to locate the data. We may request reasonable identity verification and may charge a fee permitted by law for a data access request. You may also ask a question about retention, withdraw a consent that was previously given, or opt out of direct marketing. Some information may need to be retained where applicable law or justified recordkeeping requires it.

8. Children

This corporate website and its collaboration enquiry channel are directed to organisations and adults. Children should not submit personal data through the business email address without the involvement of a parent, guardian, school, or other responsible adult.

9. Changes to this notice

We may update this notice when the website, data practices, or applicable requirements change. The effective date at the top identifies the current version. Material changes will be presented on this page before or when they take effect where practicable.

10. Privacy contact

For an informal privacy enquiry, a completed OPS003 form, or a correction request, contact the Privacy Contact at info@japality.com with the subject “Privacy request”. Do not include identity-document copies in an initial message; a suitable verification method and current postal delivery instructions can be provided if needed.